Note: This Data Processing Agreement (DPA) form part of the contract of service (verbal or written) between the Processor (Internetty Ltd) and the Controller.
This agreement is entered between:
Internetty Ltd (Also Known as PaperClip)
(Processor)
and
PaperClip Customer.
(Controller)
The Processor hereby accepts and acknowledges their role as a data processor for the Controller. The Processor hereby accepts and acknowledges their role as a data sub-processor, in the case where the Controller is also a Processor.
The processor and controller agree to:
- PaperClip will only act on the instructions of the Controller;
- PaperClip will provide access to its software platform, it is the responsibility
- of the controller to ensure their user permissions are compliant within their
- Take appropriate measures to ensure the security of processing;
- PaperClip does engage sub-processors to operate and will ensure that each sub-processor does so in accordance with the required data protection
- This will include but not limited to
- Storing information in accredited data centres or on accredited cloud based platforms like Amazon AWS;
- Ensuring information is kept encrypted where required;
- Manage access controls to the information;
- PaperClip will assist the Controller in providing subject access and allowing data subjects to exercise their rights under the GDPR;
- PaperClip will assist the Controller in meeting its GDPR obligations in relation to the security of processing, the notification of personal data breaches and data protection impact assessments;
- Delete or return all personal data to the Controller as requested at the end of the contract; and
- Submit to audits and inspections, provide the Controller with whatever information it needs to ensure they are both meeting their Article 28 obligations, and to tell the Controller immediately if it is asked to do something infringing the GDPR or other data protections law of the EU or a member
- PaperClip will retain information it is required to do so for regulatory and legal
- This will include but not limited to
Signed on Behalf of: Signed on Behalf of:
Internetty Ltd
Sarah White
Managing Director Position:
Dated: